Reports of the United States Tax Court, Volume 54United States Tax Court, 1970 - Government publications Kept up to date by a monthly publication called: United States. Tax Court. Reports. |
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Page 25
... fact payments of compensation or dividends . FINDINGS OF FACT Some of the facts have been stipulated , and those facts are so found . The petitioners , Irving Bartel and Elaine Melman Bartel , are husband and wife , who maintained their ...
... fact payments of compensation or dividends . FINDINGS OF FACT Some of the facts have been stipulated , and those facts are so found . The petitioners , Irving Bartel and Elaine Melman Bartel , are husband and wife , who maintained their ...
Page 32
... facts different from those in the case before us . In a case such as this , a slight difference in the facts may tip the balance of equities so as to bring about a different result . The petitioner refers to Arnold A. Schwartz , 40 T.C. ...
... facts different from those in the case before us . In a case such as this , a slight difference in the facts may tip the balance of equities so as to bring about a different result . The petitioner refers to Arnold A. Schwartz , 40 T.C. ...
Page 76
... FACT Some of the facts have been stipulated by the parties . The stipulated facts and the exhibits attached thereto are incorporated herein by this reference . A summary of the pertinent facts is set forth below . At the time of filing ...
... FACT Some of the facts have been stipulated by the parties . The stipulated facts and the exhibits attached thereto are incorporated herein by this reference . A summary of the pertinent facts is set forth below . At the time of filing ...
Page 107
... facts in its application for exemption and there- after in its information returns filed annually with respondent . It is well settled that in circumstances where there has been a mis- representation or omission of material facts upon ...
... facts in its application for exemption and there- after in its information returns filed annually with respondent . It is well settled that in circumstances where there has been a mis- representation or omission of material facts upon ...
Page 108
... facts . The record does not reveal whether a complete audit of petitioner's books would have fully disclosed the ... facts upon which the rulings were based or where there have been material changes in law or fact subsequent to the time ...
... facts . The record does not reveal whether a complete audit of petitioner's books would have fully disclosed the ... facts upon which the rulings were based or where there have been material changes in law or fact subsequent to the time ...
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Common terms and phrases
acquired agreement amount apply assets beneficiary Blairsville carryback cash certiorari Cicio claimed collateral estoppel Commissioner community property contract corporation cost Court Daisy Daisy's death decedent decedent's December 31 decision deduction director of internal distribution distributors district director dividend dolomitic Dredging Dri-Powr election employees entitled estate tax expenses facts Federal income tax filed follows funds GIAI gift gift tax gross estate gross income held hereinafter Income Tax Regs income tax returns interest Internal Revenue Code Internal Revenue Service issue lease lessee liability liquidation loan loss marital deduction Medco ment MGIC operating option paid parties partnership payment percent peti petitioner petitioner's premium prior purchase purposes pursuant received redemption regulations respect Respondent determined RESPONDENT Docket respondent's September 30 shareholders shares stipulated supra taxable taxpayer testamentary trust tion tioner transaction transfer trust trust instrument United wife
Popular passages
Page 423 - If an exchange would be within the provisions of subsection (b) (1), (2), (3), or (5) of this section if it were not for the fact that the property received in exchange consists not only of property permitted by such paragraph to be received without the recognition of gain, but also of other property or money...
Page 191 - Except as otherwise provided in this contract, any dispute concerning a question of fact arising under this contract which is not disposed of by agreement shall be decided by the Contracting Officer, who shall reduce his decision to writing and mail or otherwise furnish a copy thereof to the Contractor.
Page 467 - If a taxpayer receives earnings under a claim of right and without restriction as to its disposition, he has received income which he is required to return, even though it may still be claimed that he is not entitled to retain the money, and even though he may still be adjudged liable to restore its equivalent.
Page 387 - Rentals or other payments required to be made as a condition to the continued use or possession, for purposes of the trade or business, of property to which the taxpayer has not taken or is not taking title or in which he has no equity.
Page 570 - If a wife is divorced or legally separated from her husband under a decree of divorce or of separate maintenance...
Page 110 - ... filing), unless it is shown that such failure is due to reasonable cause and not due to willful neglect, there shall be added to the amount required to be shown as tax on such return 5 percent of the amount of such tax if the failure is for not more than 1 month, with an additional 5 percent for each additional month or fraction thereof during which such failure continues, not exceeding 25 percent in the aggregate.
Page 573 - ... the possession or enjoyment of, or the right to the income from, the property, or (2) the right, either alone or in conjunction with any person, to designate the persons who shall possess or enjoy the property or the income therefrom; except in case of a bona fide sale for an adequate and full consideration in money or money's worth.
Page 574 - ... where the enjoyment thereof was subject at the date of his death to any change through the exercise of a power, either by the decedent alone or in conjunction with any person, to alter, amend, or revoke, or where the decedent relinquished any such power in contemplation of his death.
Page 206 - ... for his life or for any period not ascertainable without reference to his death or for any period which does not in fact end before his death(1) The possession or enjoyment of, or the right to the income from, the property, or (2) The right, either alone or in conjunction with any person, to designate the persons who shall possess or enjoy the property or the income therefrom.
Page 756 - STOCK (a) GENERAL RULE. — If a corporation redeems its stock (within the meaning of section 317(b)), and if paragraph (1), (2), (3), or (4) of subsection (b) applies, such redemption shall be treated as a distribution in part or full payment in exchange for the stock. (b) REDEMPTIONS TREATED AS EXCHANGES. — (1) REDEMPTIONS NOT EQUIVALENT TO DIVIDENDS. — Subsection (a) shall apply if the redemption is not essentially equivalent to a dividend.